Advisory Business Leo Wealth LLC, ("Leo Wealth) is a registered investment adviser with its principal place of business located in Hurst, Texas. Leo Wealth is organized as a limited liability company ("LLC") under the laws of the State of New Jersey and as of July 1, 2021, as of the result of a merger with BFT Financial Group, LLC and The Capital Company, is now directly owned by Leo Capital Corp Holdings. Leo Wealth is made up of multiple independent offices providing advisory services under different local business names. These local offices include KMR Financial Group, and Rockwall Wealth Management. In addition, we have an office located in Hong Kong, China. During the course of the relationship with Leo Wealth our clients may also see these other business names on correspondence, performance reports and/or account statements received from their account custodians. Leo Wealth offers the following advisory services to our clients. Portfolio Management Leo Wealth offers traditional asset management services. Leo Wealth provides asset management of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's personal investment policy. We create and manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. You will authorize discretionary management in your agreement for our Asset Management Services. If you have authorized us to provide asset management services on a discretionary basis, we will make all decisions to buy, sell or hold securities, cash, or other investments in your managed account in our sole discretion without consulting with you before making any transactions. You must provide us with written authorization to exercise this discretionary authority, and you can place reasonable restrictions and limitations on our discretionary authority. We will continuously monitor your account and make trades in your accounts when necessary. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. We will monitor your account and will make management recommendations and decisions regarding buying, selling, reinvesting or holding securities, cash or other investments. Our investment recommendations are not limited to any specific productor service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. Other types of investment advisory services offered are as follows:
• Investment planning
• Asset allocation
• Selection & monitoring of affiliated and unaffiliated third-party alternative investments and private offerings
• Selection & monitoring of third-party separate account managers
• Net worth reporting We recommend that your assets be maintained in a brokerage account with Schwab, Fidelity, TD Ameritrade, or Interactive Brokers, each a FINRA registered broker/dealer and member SIPC. However, clients may select any broker-dealer of their choosing. You will appoint Leo Wealth as your investment adviser of record on specified accounts. Your account will consist only of separate account(s) held by the qualified custodian under your name. We do not act as custodian and do not have direct access to your funds and securities except to have advisory fees deducted from your account with your prior written authorization. The qualified custodian will maintain physical custody of all funds and securities of your account, and you will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) for your account. LEO ETF MODEL PORTFOLIO MANAGEMENT The following is a list of ETF model portfolios that are available to clients globally. While the model approach and exposures are similar, they are implemented using US-listed ETFs for US clients and non-US listed ETFs for non-US clients. Core ETF Models: These portfolios are comprised of ETFs that we use as building blocks to ensure widespread diversification at low cost. Our objective is to create global capital market exposure along dimensions of return that will deliver a better risk-adjusted performance in the long-term for investors. We focus on finding the most tax efficient, liquid ETFs with the lowest expense ratios. ETF selection is constantly reviewed for efficiency across cost, tracking, tax, and sustainability dimensions. We aim to take a systemic approach to investing into macro trends, tilting to exposures likely to outperform in the medium term. We do not make large bets on single positions and seek to implement the model consistently across all portfolios. The models are available in the following risk variations:
• US Focused Equity ETF will typically invest at least 80% in Equity & Commodity ETFs.
• US Focused Balanced ETF will typically invest at least 50%-80% in Equity & Commodity ETFs and up to 50% in Fixed Income ETFs.
• US Focused Moderate ETF will typically invest between 30%-70% in Equity & Commodity ETFs and between 30%-70% in Fixed Income ETFs.
• US Focused Conservative ETF will typically invest at least 50% in Fixed Income ETFs and up to 50% in Equity & Commodity ETFs.
• US Focused Dixed Income ETF will typically invest at least 80% in Fixed Income ETFs. The US-listed ETF versions of these models are available to US clients in Global and US Focused variations:
• Global will typically invest at least 50% in US stocks and bonds.
• US Focused will typically invest at least 70% in US stocks and bonds. Thematic ETF & Closed-End Fund Models: These portfolios are comprised of ETFs that focus on specific & sometimes niche areas of global markets. Our objective is to create specific exposure to target medium-term opportunities in a given sector or theme. We use ETFs as building blocks to ensure desired exposures within a particular focus at low cost. ETF selection is constantly reviewed for efficiency across cost, tracking, tax, and sustainability dimensions. The models are available in the following variations:
• Inflation Hedged Commodity Model will typically invest at least 80% in Commodity and Cryptocurrency ETFs and Closed End Funds.
• Global REITs ETF Model will typically invest at least 80% in Global Real Estate ETFs.
• Muni CEF Model will typically invest at least 80% in Municipal Bond Closed End Funds.
• Asian ETF Model will typically invest at least 80% in Asian exposure ETFs
• Liquidity Plus Model will typically invest in at least 80% in fixed maturity bond ETFs Single Stock Models: These portfolios are managed using single stocks and can have a global, regional or thematic allocation. Within each portfolio, securities are selected based on characteristics that have been well- documented in academic research to result in better risk-adjusted returns in the long-term. Key characteristics include a focus on Value, Safety, Payout, Quality, Momentum and Sentiment. Equity model portfolio is constructed using a systematic investment process that selects stocks based on above mentioned criteria. We utilize a dataset that quantitatively scores over 14,000 stocks globally on approximately 30 different sub-factors within those criteria. Stocks are then compared vs the universe and peers to enable selection into portfolios. We overlay qualitative and sustainability screens to supplement the portfolio construction process as needed. The models are available in the following variations:
• Global & US Brands Models provide exposure to large and stable household names. The models seek to identify companies that are able to preserve and grow their earnings base over the long-term.
• Global Value Model provides exposure to global large cap names. The model seeks to balance Value and Growth at a Reasonable Price characteristics.
• Global, US, UK, Europe, Hong Kong and Japan Equity Income Models provide exposure to large-cap defensive equities in their respective region. The models seek to generate sustainable and above-average dividend income streams over the long-run.
• Asian Leaders Model provides exposure to leaders within the highest growth sectors in Asia. The model seeks to invest in high Quality companies that we believe will become not only domestic and global champions over time.
• Global, US and Japan REITs Models provide exposure to real estate, seeking to build a portfolio that delivers 3-5% dividend income streams over the long-run.
• Global Healthcare provides exposure to global healthcare names.
• Global Technology provides exposure to global technology names.
• Sustainable Future Model provides exposure to companies that prioritize sustainability and innovation across the energy, healthcare, food and technology sectors. ROCKWALL MODEL PORTFOLIO MANAGEMENT The following is a list of the model portfolios that are available to clients of our Rockwall, Texas office only. Please note that these portfolios provided in our Rockwall office are not offered to other clients. RWM Conservative: Our lowest risk portfolio for clients who are willing to risk up to 5 – 10% of their portfolio in exchange for slow, incremental potential growth. Clients in this category may also need extra cash held in their account for recurring distributions. The objective of the Conservative portfolio is to provide capital preservation with limited growth. It is designed

for clients with a lower risk tolerance and whose time horizon is immediate need to five years. RWM Growth and Income: Our moderate risk portfolio - for clients who are willing to risk up to 10 - 15% of their portfolio in exchange for potential growth. This model seeks to provide capital growth through a variety of ETF’s and mutual funds, some of which pay dividend income (clients may opt to reinvest dividends). It is designed for clients with a moderate risk tolerance and whose time horizon is more than 5 years. RWM Capital: Our highest risk portfolio - for clients who are willing to risk up to 15% of their portfolio in exchange for potential growth. The model seeks to provide long-term capital appreciation utilizing a combination of ETF's, mutual funds and possibly individual stocks. It is designed for clients with a higher risk tolerance who have a longer time horizon than 5 years. RWM Jr. Conservative: For account balances under $30,000. Our lowest risk junior portfolio for clients who are willing to risk up to 5% of their portfolio in exchange for slow, incremental potential growth. Clients in this category may also need extra cash held in their account for recurring distributions. The objective of the Conservative portfolio is to provide capital preservation with limited growth. It is designed for clients with a lower risk tolerance and whose time horizon is immediate need to 5 years. RWM Jr. Growth and Income: For account balances under $30,000. Our moderate risk portfolio - for clients who are willing to risk up to 10% of their portfolio in exchange for potential growth. This model seeks to provide capital growth through a variety of mutual funds and ETF's, some of which pay dividend income (clients may opt to reinvest dividends). It is designed for clients with a moderate risk tolerance and whose time horizon is more than 5 years to distribution. RWM Jr. Capital: For account balances under $30,000. Our highest risk portfolio, for clients who are willing to risk up to 15% of their portfolio in exchange for potential growth. The model seeks to provide long-term capital appreciation utilizing a combination of ETF's, mutual funds and possibly stocks. It is designed for clients with a high-risk tolerance who have a longer time horizon than 5 years. SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS We also offer advisory management services to our clients through our Selection and Monitoring of Third-Party Money Manager programs (hereinafter, "Programs"). Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. Based on the client's individual circumstances and needs we will then perform management searches of various unaffiliated registered investment advisers to identify which registered investment adviser's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment adviser. Clients should refer to the selected registered investment adviser's Firm Brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. We monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client's objectives, we may suggest that the client contract with a different registered investment adviser and/or program sponsor. Under this scenario, our firm assists the client in selecting a new registered investment adviser and/or program. However, any move to a new registered investment adviser and/or program is solely at the discretion of the client. Leo Wealth receives a portion of the investment advisory fees by the third-party money manager for the selection and monitoring of the managers. Sub-Advisory Arrangements We may engage unaffiliated third-party sub-advisors for the purpose of assisting us with the management of a portion of its client accounts per the terms and conditions of a written Sub-Advisory Agreement between Leo Wealth and the sub-advisor. When so doing, the sub-advisor shall maintain day-to-day discretionary management authority for the assets allocated to it by us. At all times, we shall maintain both the initial and ongoing day-to-day relationship with the client, including initial and ongoing determination of client suitability for the sub-advisor’s investment strategies. The sub-advisor’s obligation shall be limited to management of the allocated assets consistent with the objective and/or strategy designated by us. The sub-advisor shall continue in such capacity until such arrangement is terminated or modified by us. Leo Wealth shall pay a portion of the investment advisory fee received for these allocated assets to the sub-advisor for its sub-advisory services. Prior to entering into a relationship, we perform a due diligence review of the subadvisor. This review includes, but is not limited to, the review of regulatory filings, compliance program, investment offerings, and the performance of the strategies considered. The due diligence process includes multiple conversations and may include in-person visits to the subadvisor’s place of business. When a strategy offered through a subadvisor is appropriate for a client of Leo Wealth, the client will be provided upon request with the subadvisor’s Form ADV, Part 2A and 2B, Privacy Notice, and any other information that may be relevant or informative to the client. The client will not engage the subadvisor directly; the client’s advisory relationship remains with Leo Wealth as set forth in the client’s Investment Advisory agreement. Leo Wealth may utilize unaffiliated third-party managers and/or unaffiliated alternative investment vehicles for the purpose of providing clients with investment options to help achieve the client’s investment objectives. Leo Wealth does not receive compensation from these managers or alternative investment vehicles, However LeoGroup Fund Services receives compensation for investments in the alternatives PIA and Niagara Typically, clients do not pay Leo Wealth a higher advisory fee as a result of any such relationships; however, for certain specialized sub-advisers/managers, clients may incur a separate fee charged directly by that sub-advisor/manager as stated in the client contract. While Leo Wealth provides investment advisory services, it does so as part of a comprehensive financial solution for our investment clients. Other services, as performed by affiliated entities, are described more fully in Item 10. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to help predict future cashflows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review state tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific productor service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. All recommendations are of a generic nature. Assets Under Management Leo Wealth has the following assets under management (“AUM”): As of December 31, 2023, Leo Wealth had $1,518,425,379 in assets under management, all of which are managed on a discretionary basis.